Whistleblowing Policy

1. PURPOSE

1.1. Anglican Preschool Services (“APS”) does not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing by staff in the course of their work. This Policy sets out the guidelines and procedures to promote responsible and secure whistle blowing without fear of adverse consequences.

1.2. The Policy aims to create a work environment where Employees and other stakeholders are able to raise concerns on unethical or illegal conduct, irregularities or malpractices, without fear of harassment and/or victimization and with an assurance that their concerns will be taken seriously and investigated, and the outcome duly communicated.

1.3. Principles and procedures of the Policy shall be communicated to all relevant stakeholders at the outset and as appropriate thereafter.

1.4. Employees should read, understand and comply with this policy. All Employees are responsible to ensure the highest standards of ethics, honesty, openness, and accountability in line with APS’s commitment to enhance good governance, transparency and safeguard the integrity of APS.

1.5. The APS’s Purpose, Vision, Mission & Values must be upheld at all times.

2. OBJECTIVES

2.1. Encourage timely reporting of illegal malpractice/misconduct.

2.2. Provide a confidential channel for escalation of concerns without fear of reprisal.

2.3. Ensure that whistle blowers are aware of their options and rights.

2.4. Ensure a consistent and timely response to improprieties reported by whistle blowers.

2.5. Ensure appropriate oversight by the Board of Directors.

2.6. Serve as a means of preventing and deterring misconduct that may be contemplated.

2.7. Protect the rights of APS.

2.8. Promote a culture of openness, accountability and integrity.

3. DEFINITIONS

3.1. “Board” means Board of Directors of APS.

3.2. “External Parties” refer broadly to, but not limited to, members of the public or those who are impacted by various organisational or business activities of APS.

3.3. “Management” means the Senior Leadership Team of APS.

3.4. “CorpGov” means the Pillar Head of Corporate Governance

3.5. “Internal Whistle Blowers” refers to Employees of APS who are expected to report incidents of misconduct involving peers, Reporting Officers or Senior Leadership Team to relevant reporting point.

3.6. “External Whistle Blowers” refers to parents, suppliers and other members of the public who report wrong doings of the organisation.

4. REPORTING PROCEDURES

4.1. APS encourages Employees and External Parties to put their names to their allegations whenever possible. Concerns or irregularities expressed anonymously are more difficult to act upon effectively but they will be considered, taking into account the following:

4.1.1. Seriousness of the issues raised.

4.1.2. Significance and credibility of concerns.

4.1.3. Likelihood of confirming the allegation from attributable sources and information provided.

4.2. All valid concerns or irregularities raised will be acknowledged and treated with confidence throughout the process.

4.3. Concerns may be raised verbally or in writing. As it is essential for APS to have all critical information in order to be able to effectively evaluate and investigate a complaint, the report should provide as much detail and be as specific as possible. All concerns raised in writing shall be sent to: informus@anglicanps.edu.sg.

4.4. The CorpGov, or whoever as appointed by the CEO, shall be the point recipient of all incident reported. All cases of fraud, potential criminal activities and money laundering activities, as well as allegations involving a member of the Management or the Board shall be immediately escalated to the Chairman of the Board.

4.5. APS prohibits discrimination, retaliation, or harassment of any kind against a whistle blower who submits a complaint or report in good faith. If a whistle blower believes that he or she is subject to discrimination, retaliation, or harassment for having made a report under this Policy, he or she should immediately report those facts directly to the CorpGov, or to the CEO should the discrimination, retaliation, or harassment comes from the CorpGov. Reporting should be done promptly to facilitate investigation and the taking of appropriate action.

4.6. At the appropriate time, the whistle blower may need to come forward as a witness. If an Employee or External Party makes an allegation in good faith but it is not confirmed by the investigation, no action will be taken against him or her. If, however, an Employee has made an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against him or her. Likewise, if investigations reveal that the External Party making the complaint had done so maliciously or for personal gain, appropriate action, including reporting the matter to the police, may be taken.

4.7. All information disclosed during the investigation will remain confidential, except as necessary or appropriate to conduct the investigation and to take any remedial action, in accordance with any applicable laws and regulations.

4.8. APS reserves the right to refer any concerns or complaints to appropriate external regulatory authorities. Depending on the nature of the complaint, the subject of the complaint may be informed of the allegations against him or her and be provided with an opportunity to reply to such allegations. Employees who fail to cooperate in an investigation, or deliberately provide false information during an investigation, shall be subject to strict disciplinary action up to, and including, immediate dismissal.

4.9. If, at the conclusion of an investigation, APS determines that a violation has occurred or the allegations are substantiated, appropriate disciplinary action in accordance with the Employment Terms Handbook will be taken. Non-anonymous whistle blowers will be informed that action has been taken at the conclusion of the investigation, without divulging confidential information.

5. Handling of External Media

5.1. In disclosing to external media with regards to alleged misconduct through the whistle blowing channels, APS will ensure that there is fairness and objectivity in its corporate statements with no misrepresentation and unprofessional pursuit of publicity.

5.2. Where information is confidential, APS shall not, except in the course of duty or under compulsion by law, disclose, divulge, or make public any information of a confidential nature relating to the details of the alleged misconduct.

5.3. During the investigation, the whistle blower or any party privy to the confidential information shall not inform external media or any other persons.

6. Implementation & Revision Dates

6.1. The Policy was drafted for review on 26 April 2022, and approved by the Board on 24 November 2022.

6.2. The Policy shall be reviewed regularly, where APS may modify this Policy to maintain compliance with applicable laws and regulations or accommodate organisational changes. This review should be carried out by the SLT.

6.3. APS’s Audit Committee should review management compliance with this policy and procedures and recommend improvements or updates as necessary towards its continued effectiveness.